An audit ending doesn't necessarily mean the story is over. If you disagree with the examiner's conclusions, IRS Appeals is your next step, and it is a step worth taking seriously rather than skipping.
Here is how that process generally works.
1. Appeals is a separate, independent office
The IRS Independent Office of Appeals is structurally separate from the examination division that conducted your audit. Its stated mission is to resolve disputes without litigation, and in practice, appeals officers often have more flexibility to consider the hazards of litigation than the original examiner did.
This separation matters. You are not simply asking the same person to reconsider. You are getting a fresh set of eyes.
2. You need a timely, well-supported protest
After an audit concludes with proposed changes you disagree with, you generally have a limited window to file a written protest requesting an appeal. This protest needs to lay out specifically which adjustments you dispute and why, supported by facts and, where relevant, legal authority.
A protest that just says "I disagree" accomplishes very little. One that walks through the facts and the law gives the appeals officer something to work with.
3. Appeals officers weigh litigation risk
Unlike the examiner, an appeals officer is generally authorized to consider how a case might play out if it went to Tax Court, including the government's own risk of losing on a particular issue. This can open the door to a negotiated resolution that reflects genuine uncertainty in the law or the facts.
This is often where a well-prepared case sees real movement, even when the audit itself felt like it went poorly.
4. Most cases settle at this stage
The majority of disputes that reach Appeals are resolved there, without ever going to Tax Court. That doesn't mean every taxpayer gets everything they want, but it does mean there is a real opportunity to reduce or eliminate proposed adjustments before litigation becomes necessary.
Going in prepared, with a clear and organized position, significantly improves your odds.
5. If Appeals doesn't resolve it, litigation is still an option
If you cannot reach an agreement at Appeals, you generally still have the right to petition Tax Court, assuming you act within the applicable deadlines. Appeals is not your last chance, but it is usually your best chance to resolve things without the time and expense of litigation.
Treating it as a genuine opportunity, rather than a formality, tends to produce better outcomes.
If your audit ended with results you don't agree with, reach out through blgattorney.com or call my Oklahoma City office. Let's build the strongest possible protest before your deadline passes.